OIG alleged that Salinas paid remuneration to a health care company owned and operated by two physicians on staff at Salinas. OIG further alleged that the remuneration paid took the form of payments under an arrangement for Salinas to pay the health care company to rent a laser when the laser was not needed by Salinas because a second laser had been purchased by Salinas for its own use. OIG contended that Salinas failed to discontinue the arrangement after purchasing its own laser because continued payments to the health care company took into account the value of the company owners' referrals.

OIG alleged that St. Agnes paid remuneration to a cardiology practice in the form of equipment, supplies, staff and space needed to provide certain nuclear diagnostic cardiology testing services. OIG alleged that the cardiology practice paid St. Agnes less than fair market value for these services.